Privacy Policy

Last modified: April 28, 2011

This Privacy Policy applies to all of the applications, products, services and websites offered by LuckyLabs Inc. or its subsidiaries or affiliated companies. Sometimes, we may post product specific privacy notices or other materials to explain our products in more detail.

If you have any questions about this Privacy Policy, please feel free to contact us through our website or write to us at

Privacy
c/o LuckyLabs Inc.
376 Boylston Street, Suite #501
Boston, MA 02116
USA

Information we collect and how we use it

We may collect the following types of information:

• Information you provide — When you sign up for some of our products, we ask you for personal information. We may combine the information you submit under your account with information from other LuckyLabs services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.
• Cookies — When you visit LuckyLabs, we send one or more cookies to your computer or other device. We use cookies to improve the quality of our service, including for storing user preferences, improving products and ad selection, and tracking user trends, such as how people use our services. LuckyLabs also uses cookies in its advertising services to help advertisers and publishers serve and manage ads.
• Log information — When you access LuckyLabs services via a browser, application or other client our servers automatically record certain information. These server logs may include information such as your web request, your interaction with a service, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser or your account.
• User communications — When you send email or other communications to LuckyLabs, we may retain those communications in order to process your inquiries, respond to your requests and improve our services. When you send and receive SMS messages to or from one of our services that provides SMS functionality, we may collect and maintain information associated with those messages, such as the phone number, the wireless carrier associated with the phone number, the content of the message, and the date and time of the transaction. We may use your email address to communicate with you about our services.
• Affiliated LuckyLabs Services on other sites — We offer some of our services on or through other web sites. Personal information that you provide to those sites may be sent to LuckyLabs in order to deliver the service. We process such information under this Privacy Policy.
• Third Party Applications — LuckyLabs may make available third party applications, such as gadgets or extensions, through its services. The information collected by LuckyLabs when you enable a third party application is processed under this Privacy Policy. Information collected by the third party application provider is governed by their privacy policies.
• Location data — LuckyLabs offers location-enabled services, sometimes part of another application or game. If you use those services, LuckyLabs may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location (such as a cell ID).
• Unique application number — Certain services include a unique application number that is not associated with your account or you. This number and information about your installation (e.g., operating system type, version number) may be sent to LuckyLabs when you install or uninstall that service or when that service periodically contacts our servers (for example, to request automatic updates to the software).
• Other sites — This Privacy Policy applies to LuckyLabs services only. We do not exercise control over sites that include LuckyLabs applications, products or services, or links from within our various services. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you.

In addition to the above, we may use the information we collect to:

• Provide, maintain, protect, and improve our services (including advertising services) and develop new services; and
• Protect the rights or property of LuckyLabs or our users.

If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.

LuckyLabs processes personal information on our servers in the United States of America and in other countries. In some cases, we process personal information outside your own country.

Choices

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some LuckyLabs features and services may not function properly if your cookies are disabled.

LuckyLabs' services, unless otherwise noted, are generally not intended for people under the age of 13. We encourage minors over the age of 13 to seek permission from their parents before using our services.

Information sharing

LuckyLabs only shares personal information with other companies or individuals outside of LuckyLabs in the following limited circumstances:

• We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
• We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of LuckyLabs, its users or the public as required or permitted by law.

If LuckyLabs becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we may transfer your information to the new owner so that our services can continue to operate.

Information security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information to LuckyLabs employees, contractors and agents who need to know that information in order to process it on our behalf. When bound by confidentiality obligations, these individuals may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Accessing and updating personal information

When you use LuckyLabs services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

Enforcement

LuckyLabs is new, but we plan to fully participate in the Safe Harbor program developed by the U.S. Department of Commerce.

LuckyLabs regularly reviews its compliance with this Privacy Policy. When we receive formal written complaints, it is LuckyLabs' policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between LuckyLabs and an individual.

Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice.